Similar case. Not sure that it is your text. The term used is "written observations"
http://diposit.ub.edu/dspace/bitstream/2445/122626/1/WP_2018... (page 5)
1. Introduction
In 2008, the Spanish government believed that Spain was among the national legal
systems that offered the strongest protection to consumers in respect of (legislative)
safeguards against unfair contract terms.1
1 **Written observations** of the Kingdom of Spain, submitted to the CJEU in Case C-40/08 Asturcom on 11 August 2008 (**Observaciones del Reino de España** en el asunto C-40/08 Asturcom; not published).